Maria Victoria Socorro Lontoc-Cruz vs.

Nilo Santos Cruz

G.R. No. 20198
October 11, 2017

FACTS
 Marivi at 22 met Nilo, 28, sometime in March 1986. Nilo, whose job was then in Hong Kong,
prodded Marivi to marry him. The couple married in a civil ceremony on October 21, 1986
followed by a church wedding on February 8, 1987. The marriage produced two sons: Antonio
Manuel and Jose Nilo.
 On July 7, 2005, Marivi filed a petition for declaration of nullity of marriage based on
psychological incapacity.
 Marivi cited the following:
o His infidelity and his non-commitment to the marriage;
o The lack of 'oneness' in the marriage;
o The lack of sexual contact for more than a decade as Nilo made excuses;
o Putting up a facade that he is a caring, concerned, and loving husband, especially to his
bosses; and
o Preference towards the company of his peers/friends.
 Nilo claimed he was not singularly responsible for the breakdown of their marriage. He stressed
that Marivi also contributed to the deterioration of their union:
o Marivi would demand that he behave in ways he was not accustomed to or inconsistent
with his career position;
o Marivi was jealous of his friends and would often make hasty conclusions that he was
having an affair;
o Marivi would exhibit volatile temperament if things did not go her way;
o Marivi would make decisions impulsively;
o She lacked respect for Nilo, and would speak to him degradingly, and even accuse him
of being gay or a homosexual.
 On October 11, 2006, the trial court rendered a Partial Decision approving the parties'
Compromise Agreement pertaining to custody, support, and dissolution of the properties. Trial
on the issue of the nullity of marriage on the ground of psychological incapacity ensued.
THE CLINICAL FINDINGS
The petitioner presented Dr. Cecilia Villegas, a psychiatrist, and Dr. Ruben Encarnacion (Dr.
Encarnacion), a clinical psychologist.
 Dr. Villegas diagnosed Nilo to have "inadequate personality disorder related to masculine
strivings associated with unresolved oedipal complex," while she diagnosed Marivi to have
"personality disorder of the mixed type, histrionic, narcissistic, with immaturity”
 The root cause of the above clinical conditions, on the part of Marivi Cruz, were the
overindulgence and over attention of her parents.
 On the part of Nilo Cruz, his negative identification and resentments towards his father and
close attachments to his mother, continued by his long-time maid, to the point of an oedipal
situation led to his inadequacy, along masculine strivings, with difficult assertions of his
authority and power.
  According to Dr. Villegas, both parties could not tolerate each others' weaknesses and that the
incapacities of the parties are grave because they preferred to satisfy their own needs rather
than to give in to the other's needs.
 Dr. Encarnacion supported Dr. Villegas' diagnosis and concluded that there was no chance of a
successful marriage in a dysfunctional union when there is double psychological incapacity. He
categorically stated that Nilo was incapable of being a good husband and a good father.
 As for Marivi, Dr. Encarnacion found that she exhibited "Histrionic Personality Behaviors and
Features" and stated that Marivi's "inflexibility" consisted in her expecting a high standard of
faithfulness from all men as exemplified by her dad, who was also very devoted to her mother.
However, because dissatisfied and frustrated by her actual marital situation, she sought
attention, externalized blame, displayed anger, mistrust, resentment, and self-indulgence.
RULING OF THE REGIONAL TRIAL COURT
 On October 13, 2008, the RTC denied the petition.
 The court noted that Marivi's need for assurance that she is loved, vis-a-vis her looking up to her
father as her standard, was not by itself sufficient to declare her psychologically incapacitated.
 As for Nilo, the RTC held that prioritizing his work over the emotional needs of his family was not
reflective of his psychological incapacity because what he did was still for his family's benefit.
 From the RTC's verdict, petitioner appealed to the CA.
RULING OF THE COURT OF APPEALS
 On November 22, 2011, the CA united with the RTC, found that Dr. Villegas and Dr. Encarnacion
failed to paint a clear picture of the supposed gravity or seriousness of Nilo's psychological
incapacity.
 Court believes that the protagonists in this case are in reality simply unwilling to work out a
solution for each other's personality differences, and have thus become overwhelmed by
feelings of disappointment or disillusionment toward one another. Sadly, a marriage, even if
unsatisfactory, is not a null and void marriage.
 The CA thereafter disposed of the appeal. WHEREFORE, the appeal is DENIED. The decision of
the Regional Trial Court in CV No. 05-095 denying the petition for declaration of nullity of
marriage between appellant Maria Victoria Socorro Lontoc-Cruz and appellee Nilo Santos Cruz
for insufficiency of evidence is hereby AFFIRMED. No cost.